I'm interested to know if I can use this tax mode as a software consultancy company - essentially doing a custom software development in a form of licensing it (instead of selling development hours) to clients. Most of the sources I read state that this also applies software, but there are no specifics.

I'm specifically interested in Luxembourg, Netherlands, Liechtenstein and Malta.

Here is some info (page 8): http://ftp.zew.de/pub/zew-docs/dp/dp13070.pdf

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    I'm not following your question - Are you asking if it's OK, or if it's recommended? If the latter, how would we determine what's recommended in your case? – Canadian Luke Feb 2 '15 at 17:57
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    The goal is to lower my tax burden in a legal way. If there is such a way, it would be stupid not to use it. This tax mode (for IP) has much lower % than other type of income. My question is if I can use this tax mode for my case. – Sergey Feb 3 '15 at 19:45

Yes, you can!

You will just have to be sure that the cost of running such a construct is less than what you gain from it.

Such IP/license/ptent boxes usually involve setting up multiple companies in different countries. Setting up a company means in many jurisdictions these days that you need to rent some kind of office (yes, can be some kind of shared office providers, but just a PO box won't do) in each country, set up the company there and keep it maintained, i.e. do tex returns and the like.

It may make sense. And it may be very interesting work if this kind of work is fun to you. But it will mean a lot of new tricks you have to learn. There is no one-stop shop for constructs like this.

And beware of providers who want to make you believe it is as simple as giving them your credit card details and purchase some "premium EU/offshore company package". In many cases all they care about it to generate work for any kind of legal advisors and you may end up with a buch of contracts and half-way operational businesses that will cause you more issues than they solve.

On the other hand, if you are in a high tax country and we are talking some millions of EUR / USD / GBP here, I'd go for it.

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